K&L Gates Triage: 340B Regulatory Update: CMS Proposal and Draft Executive Order Could Have Big Impact on 340B Program
K&L Gates Triage: 340B Eligibility - Hospital Covered Entities
On November 16, the Centers for Medicare & Medicaid Services (CMS) published its Medicare Physician Fee Schedule (PFS) final rule for calendar year 2024 (PFS Final Rule). According to the CMS press release, the PFS Final Rule...more
The Healthcare Real Estate Team at Sheppard Mullin attended the SoCal Healthcare Real Estate Summit on October 18, 2023. This event offered valuable insights into critical issues for health systems and those involved in...more
The Centers for Medicare & Medicaid Services (“CMS”) announced it is expanding access to behavioral health services for Medicare beneficiaries through intensive outpatient services coverage. In general, Medicare will cover...more
Last week, the Centers for Medicare & Medicaid Services (CMS) released the two major regulations we all were waiting for: the Calendar Year (CY) 2024 Physician Fee Schedule (PFS) proposed reg and the CY 2024 Outpatient...more
Catalyzed by the COVID-19 pandemic, many behavioral health care providers have implemented telehealth services to augment existing partial hospitalization programs (PHPs) and intensive outpatient programs (IOPs). In a new...more
I. Certificate of Need Program - A. AL2021-053, The Clubhouse Autism & Developmental Learning Center, LLC, Jackson, AL: Proposes to establish a multi-specialty outpatient pediatric rehabilitation facility providing speech...more
At long last, the Centers for Medicare and Medicaid Services (CMS) has issued decisions on provider applications for the mid-build exception. Nearly four years after the deadline for hospitals to apply for the mid-build...more
While health practitioners work to manage COVID-19, the healthcare industry itself is being transformed by the challenges and opportunities of the pandemic. Hospitals are restructuring to meet fluctuating inpatient care...more
In case you missed it, the Connecticut Department of Public Health (DPH) issued two Orders last week affecting patients with disabilities and patients who are minors in certain health care facilities. Both Orders went into...more
On May 7, 2020, the Mississippi State Department of Health (“MSDH”) issued a State Health Officer’s Order relaxing its April 24, 2020 Order regarding the provision of outpatient medical services and elective surgeries and...more
The Connecticut Office of Health Strategy (OHS) issued its third guidance document related to CON requirements related to the COVID-19 pandemic on March 25, in which OHS waives CON approval requirements for hospitals seeking...more
On March 30, 2020, the Centers for Medicare and Medicaid Services (CMS) released a Quality, Safety & Oversight Group (QSO) memorandum (QSO-20-22-ASC, CORF, CMHC, OPT, RHC/FQHCs) addressing standards for infection control and...more
CMI, CMMI, and Changing the Consumer Experience in the U.S. and China - Case Mix Index: Sitting in multiple hospital, payor and physician organization presentations at the J.P. Morgan healthcare conference this year, it is...more
On July 9, 2019, Connecticut Governor Ned Lamont signed into law Public Act No. 19-118 “An Act Concerning the Department of Public Health’s Recommendations for Various Revisions to the Public Health Statutes” (PA 19-118). ...more
Hospitals with off-campus provider-based departments (PBDs) may want to rethink their end of summer vacation plans in order to focus on a recent slate of proposed regulations from the Center for Medicare and Medicaid Services...more
On June 12, 2018, Connecticut Governor Dannel P. Malloy signed into law Public Act No. 18-149 “An Act Concerning Outpatient Clinics, Urgent Care Centers and Freestanding Emergency Departments” (PA 18-149). This legislation...more
Several provisions in the recently adopted 2018-19 New York State Budget (the “Enacted Budget”) are intended to address the ongoing opioid crisis. As discussed in a prior post, some were focused on pharmaceutical...more
“Therapy caps” date back to the Balanced Budget Act of 1997, which limited (or “capped”) the amount of annual per-patient therapy expenditures under Medicare Part B. However, Congress created an exceptions process in 2006,...more
2017 was another challenging year for hospitals grappling with site-neutral payment changes for off-campus provider-based hospital outpatient departments (OCPBDs). ...more
In a previous blog post, we began to dissect the new Massachusetts State Senate bill, “An Act Furthering Health Empowerment and Affordability by Leveraging Transformative Health Care,” and focused on a provision that would...more
In some states, including the Commonwealth of Massachusetts, “site neutrality” for outpatient hospital reimbursement is factoring into state-specific health reform and cost containment initiatives. This potentially goes...more
I. For Informational Purposes Only - Contested Case - AL 2017-024, The Troy Hospital Health Care Authority d/b/a Troy Regional Medical Center, Troy, Alabama: Proposes to acquire, relocate and operate 18 geriatric...more
CMS recently proposed to reduce the facility fee for non-excepted off-campus provider-based hospital departments (OPBDs) from 50 percent of the Medicare Physician Fee Schedule (MPFS) amount to 25 percent of the MPFS amount....more
Connecticut Governor Dannel P. Malloy recently signed into law Public Act 17-241 (PA 17-241), which contains provisions concerning facility fees, the sending and receiving of electronic health records between hospitals and...more